Chapter 3

Question 1

AML/CFT policies:

4

Answer 1

1. Clear and simple High-Level Statements Uniform across entire Organization.
2. Sets the Tone from the Top.
3. Approved by Executive Management or BOD
4. Reflects the High-Level Responsibilities of the Stakeholders of Organization

Question 2

AML/CFT procedures:

6

Answer 2

1. Translates policies into acceptable and workable practice
2. Tasks stakeholders with respective responsibilities
3. May be established at the operational (not executive) level of the FI.
4. Instructions on how an institution wants something done.
5. More detailed than AML policies.
6. Reviewed and updated regularly.

Question 3

AML/CFT controls

3

Answer 3

1. Internal technology/tools the FI utilized to ensure AML/CFT program is functioning as intended within predefined parameters.
2. Alerts compliance to potential outliers/deviations from normal policy that may need to be reviewed.
3. Includes management reports, automated review systems, or utilization of multiple reviewers.